* A: The purchase of high-value real estate using cash in multiple transactions-especially without clear economic justification-is a classic money laundering typology. The goal is typically to integrate illicit funds into the legitimate economy and obscure their origin.
* "Large cash purchases of property without an obvious economic rationale are a significant red flag for money laundering in the real estate sector."
* This typology is highlighted in CAMS 6th Edition and the FATF's guidance on real estate ML/TF risks.
References:
CAMS 6th Edition, Real Estate and ML Typologies
FATF, Money Laundering and Terrorist Financing through the Real Estate Sector

According to the FATF Guidance on Private Sector Information Sharing, FIs should establish sufficient safeguards concerning the confidentiality of information shared for AML purposes, both within the same financial group and between FIs not belonging to the same group. These safeguards include ensuring that the information is shared only with authorized personnel who have a need to know, that the information is used only for the intended AML purpose, and that the information is protected from unauthorized access, disclosure, or misuse. FIs should also comply with the applicable legal and regulatory requirements on data protection and privacy, and respect the rights and interests of the customers whose information is shared1.
1: FATF Guidance on Private Sector Information Sharing1

A: Geographic risks should be used to identify the priority of the Fl in this scenario. According to the CAMS Manual (6th Edition), "Geographic risk refers to the possibility that the location of a customer, transaction, or product may increase the likelihood of money laundering or terrorist financing because of weak or nonexistent AML/CFT controls" (p. 59). In this scenario, the expansion to an area of the world with weak AML laws would increase the Fl's geographic risk.
Reference: Certified Anti-Money Laundering Specialist (the 6th edition), Section 3.2.3 Geographic Risks, p.
59.

Evaluating the risk scoring model and conducting the risk assessment itself may need to be performed annually, every eighteen to twenty-four months, before the launch of a new product, or when an acquisition of another financial institution occurs.
Reference: https://www.wolfsberg-principles.com/sites/default/files/wb/pdfs/faqs/17.%20Wolfsberg-Risk- Assessment-FAQs-2015.pdf (10)